As of 1st January 2026, the Carbon Border Adjustment Mechanism (CBAM) has entered into force with full compliance obligations. Within a week, a substantial change was proposed, undermining a framework that took years to agree on and implement: Article 27a, which introduces an open‑ended, possibly retroactive suspension mechanism for some products in the CBAM list.

While this article may seem like a potential opportunity for the sectors concerned by the suspension, it will actually cause uncertainty, unpredictability and a potential loss of billions of investments for sectors such as low-carbon ammonia, steel and fertilisers – especially due to its possible retroactivity.

Hydrogen Europe and 5 other organisations representing clean hydrogen, ammonia, fertilisers, have sent a joint letter to the European Parliament’s ENVI committee calling for the removal of such article from the CBAM revision.

CBAM was designed to support climate ambition and competitiveness. Article 27a risks doing the opposite, creating uncertainty for first movers and disincentivising carbon pricing globally. Europe needs policy stability to unlock billions in clean industrial investment. Removing Article 27a is essential to protect the credibility of the CBAM and keep Europe on track for a resilient, low-carbon future.

Read the full letter below: